The $2.9bn fine handed down to Goldman Sachs over their role in #1MDb scandal is hugely welcome, so to is news of individual protection.

However - serious questions remain to be asked about UK enforcement and regulators

Here's why

(THREAD)

FCA & PRA both handed $63m fines to Goldman Sachs' London subsidery GSI . Final notices reveal:

- GSI was "arranger, initial purchaser and underwriter" of #1MDb transactions
- The bank's $547 million profit from #1MDb was booked to GSI (with all but $91m transfer priced out)

In 2013, GSI senior personnel in London were told about possible bribery in the #1MDb deal. The FCA notice lays out a series of serious failings at GSI in relation to this alleged bribery - failing to deal with the allegations adequately or escalate them to 'control functions'.

Not the only London connection - a crucial meeting between key intermediary Jho Low (currently being sought by US prosecutors) and the Goldman employees facing prosecution in the US took place here in 2012.

Did regulators and enforcement properly consider investigating and prosecuting GSI for failure to prevent bribery?
Why haven't they announced any action against these 'senior personnel' based in GSI in London for serious failings such as reviewing 'approved person' status?

Regulatory fines are not enough to deter corrupt activity where criminal fines can be imposed. @freehills event survey of lawyers working on corporate crime this week showed close to 70% agree that companies and banks need to be held criminally liable.

Regulatory action is particularly inappropriate where there are widespread failings across a firm. @goldmansachs is already under investigation through a review ordered by the @pra into whether its regulatory reporting is adequate: https://www.ft.com/content/2b04f78e-2fcf-11ea-a329-0bcf87a328f2

Individuals in positions of responsibility also need to face consequences for the kind of serious failings @fca and @pra uncovered at GSI in the #1MDb case.